Maddalena Cecci on Trusts e Attività Fiduciarie Activities comments on recent case law on the subject of proof of trust interposition in the face of the traceability of the chain of control to the settlors

6 June 2023

In the journal Trusts e Attività Fiduciarie (No. 3/2023), Maddalena Cecci presents the ruling of the Piedmont CTR that upheld the notices of assessment served on the settlors of two trusts based in Singapore, in order to recover for taxation the higher foreign source income formally owned by these trusts-holders of financial assets in Switzerland and placed at the top of a chain of control ending with Italian companies-to be substantially traced back to the settlors, given the proven interposed nature of the trusts themselves.